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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20055C0531982-08-0606 August 1982 Response to Interrogatories Re Safety Evaluation on full-scale Sleeving.Certificate of Svc Encl ML20058D5771982-07-21021 July 1982 First Interrogatories & Request for Production of Documents Re Safety Evaluation of full-scale Sleeving.Related Correspondence ML20054L9861982-07-0707 July 1982 Response to First Interrogatories & Request for Production of Documents Re 820416 Ler.Certificate of Svc Encl ML20054J1241982-06-21021 June 1982 Response Objecting to Wi Environ Decade Second Set of Interrogatories & Request for Production of Documents Re full-scale Sleeving Program.Affidavit & Certificate of Svc Encl ML20052C4641982-04-30030 April 1982 Supplemental Responses to Wi Environ Decade First Interrogatories & Request for Production of Documents Re full-scale Sleeving Program ML20052C4671982-04-30030 April 1982 Response to Wi Environ Decade First Interrogatories & Request for Production of Documents Re full-scale Sleeving Program.Certificate of Svc Encl ML20050A8301982-03-27027 March 1982 Second Supplemental Answer to License & NRC First Interrogatories Re full-scale Sleeving.Related Correspondence ML20049H8401982-03-0101 March 1982 Response to Wi Environ Decade First Interrogatories & Request for Production of Documents on full-scale Sleeving Program.Affidavit & Certificate of Svc Encl ML20041A0831982-02-10010 February 1982 First Interrogatories & Request for Production of Documents Re full-scale Sleeving Program.Related Correspondence ML20039E1841981-12-13013 December 1981 Requests for Admissions of Fact.Notices of Appearance & Certificate of Svc Encl ML20039A1871981-12-0707 December 1981 Answer to Licensee Second Set of Interrogatories Re full- Scale Sleeving.Related Correspondence ML20011A6431981-10-24024 October 1981 First Interrogatories & Request for Production of Documents to Licensee on Demonstration Sleeving Program ML20027A5601978-11-14014 November 1978 St of Wi'S Answers to NRC Staff'S First Set of Interrogs & Request for Production of Documents.St Has Not Yet Located Qualified Witnesses Re Admitted Contentions.Cert of Svc Encl ML19289C2041978-11-13013 November 1978 Swears That Listed Persons Have Been Authorized by Intervenors Lacse to Respond to Interrogs Submitted by NRC Staff & Applicant Wiep Re Lacse Contentions ML20027A4461978-11-0808 November 1978 Applicant'S Answers to 780929 NRC Interrogs Re Amend to Lic#DPR-24 & #DPR-27,Increasing Spent Fuel Storage Capacity. W/List of Names,Background & Professional Quals of Witnesses & Answers Re Potential Incremental Airborne Releases ML20027A3801978-11-0101 November 1978 Applicant Wiep'S Answers to Interrogatories Propounded by St of Wi on 781002 Re Amend to Lics for Subj Facils to Increase Spent Fuel Storage Capacity.Supporting Documentation & Cert of Svc Encl ML20027A3281978-10-27027 October 1978 Applicant'S Answers to Interrogs Propounded by Intervenor on 780927. Cert of Svc Encl ML20027A3511978-10-26026 October 1978 Lakeshore Citizens for Safe Energy Responses to the Wi Elec Pwr Co'S First Set of Interrogs. Defines Increased Worker Activity Re Spent Fuel Pool Activities ML20027A3521978-10-25025 October 1978 Lakeshore Citizens for Safe Energy Responses to the NRC Staff'S First Set of Interrogs. Urges Evaluation of Airborne Emissions Which Add to Existing Background Radiat. Cert of Svc Encl ML20027A1621978-10-0202 October 1978 Interrogatories to Applicant Re Maint of Spent Fuel Pool & Danger from Radiation Emissions & Exposures ML20027A1601978-10-0202 October 1978 Interrogatories Re NRC Position on Technical Merits of Intervenor,Lakeshore Citizens for Safe Energy,Admitted Contentions ML20147B4511978-09-27027 September 1978 Interrogatories Propounded to Applicant Re Environ & Safety Aspects of Proposed Facil 1982-08-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARNPL-97-0357, Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems1997-06-19019 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems DD-97-15, Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request1997-06-18018 June 1997 Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request ML20141B0451997-06-0909 June 1997 Requests Extension of Comment Period for NRC Bulletin 96-001,suppl 1 Re Control Rod Insertion Problems ML20198R1511997-03-0505 March 1997 Transcript of 970305 OI Interview of Aj Cayia in Two Rivers, Wi Re NRC Investigation Case 3-97-008.Pp 1-70 ML20198R1361997-03-0404 March 1997 Transcript of 970304 OI Interview of DF Johnson in Two Rivers,Wi Re NRC Investigation Case 3-97-008.Pp 1-37 ML20198R0931997-03-0404 March 1997 Transcript of 970304 OI Interview of Rj Harvey in Two Rivers,Wi Re NRC Investigation Case 3-97-008.Pp 1-28. Supporting Documentation Encl ML20198R1111997-03-0404 March 1997 Transcript of 970304 OI Interview of E Ziller in Two Rivers, Wi Re NRC Investigation Case 3-97-008.Pp 1-33.Supporting Documentation Encl ML20198R1281997-03-0404 March 1997 Transcript of 970304 OI Interview of T Malanowski in Two Rivers,Wi Re NRC Investigation Case 3-97-008.Pp 1-28 ML20134B7371997-01-27027 January 1997 Exemption from Requirements of 10CFR50.60 to Determine That Setpoint for LTOP Events Will Not Present Undue Risk to Public & Safety.Exemption Granted NPL-95-0321, Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p)1995-07-11011 July 1995 Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p) ML20085E6541995-06-13013 June 1995 Comment Re Draft NUREG/BR-0199, Responsiveness to Public. Expresses Concern on Dry Cask Storage W/Exemption Given to VSC-24 Cask & Procedures for Unloading & Transport at Plant ML20078F4831994-12-20020 December 1994 Comment on Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Np Reactors.Informs That Util of Belief That NRC Already Has Appropriate Regulatory Authority Over Shutdown & low-power Operations,As Provided in Maint Rule ML20077E8361994-12-0101 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low- Power Operations for Nuclear Power Reactors ML20059E9331993-10-27027 October 1993 Comment Supporting Proposed Rule 10CFR171 Re Restoration of Generic Exemption from Annual Fees for Nonprofit Educational Institutions ML20045D7331993-06-13013 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Recommends That NRC re-evaluate Proposed Testing Frequency Due to Random Testing Rate of 50% Sufficient to Provide Continued Detection Effectiveness ML20127D7191992-09-0606 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule ML20127D6371992-09-0303 September 1992 Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule & Urges NRC to Extend Comment Period in Order for Concerned Citizens to Prepare Thorough List of Objections ML20114D2591992-08-24024 August 1992 Comment Opposing Proposed Rule 10CFR72 Re Proposal to Store Spent Nuclear Fuel in VSC-24 Storage Casks at Plant in State of Wi ML20073N1141991-05-10010 May 1991 Comment Supporting Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery ML20058D4831990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20235S8381989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Degree Requirement for Senior Reactor Operator (Sro).Unless Grandfathered in Next 4-5 Yrs Author to Be Locked Out of Job & Does Not Intend Spending 20 Plus Yrs as Reactor Operator ML20235N8341989-02-17017 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants ML20148K5591988-03-18018 March 1988 Comment Supporting Proposed Rule 10CFR50,App J Re Mass Point Method of Data Analysis.Recommends Test Duration Criteria in ANSI/ANS-56.8-1987,Section 5.4 Be Accepted in Revised Regulations ML20236Q7991987-11-0909 November 1987 Comments on Proposed Rev 2 to Reg Guide 1.100 Re Seismic Qualification of Electrical & Mechanical Equipment for Nuclear Power Plants ML20235V8231987-10-13013 October 1987 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violations Noted During Special Physical Security Insp on 860718-0807 ML20136E0511985-11-20020 November 1985 Memorandum & Order Granting Licensee 850826 Request for Extension of Deadline for Environ Qualification of Electrical Equipment to 860525 for Unit 1 & 851231 for Unit 2.Served on 851120 ML20137C8601985-11-19019 November 1985 Transcript of Commission 851119 Affirmation/Discussion & Vote in Washington,Dc Re SECY-330(a) on Point Beach & SECY-225(a) on Sequoyah.Pp 1-5 ML20138M8711985-10-25025 October 1985 Transcript of 851025 Meeting in Washington,Dc Re Util Requests for Exemption from Environ Qualification.Pp 1-76 ML20078L1661983-10-17017 October 1983 Response Opposing Wisconsin Environ Decade 830923 Petition for Review of ALAB-739 Re Steam Generator Tubes Repaired by Sleeving.Nexus Between Sleeving & Tube Failure Shown. Certificate of Svc Encl ML20078C8801983-09-23023 September 1983 Petition for Review of Aslab 830907 Decision on Sleeving Degraded Steam Generator Tubes.Aslab Erroneously Denied Nexus Shown Between Sleeving & Tube Failure.Certificate of Svc Encl ML20076E1581983-08-22022 August 1983 Response Opposing Wisconsin Environ Decade 830811 Request to Respond to Hf Conrad Affidavit.Aslab Affirmed Dismissal of Decade Petition to Intervene.Decade Thus Lacks Party Standing.Certificate of Svc Encl.Related Correspondence ML20204G3481983-04-29029 April 1983 Brief Opposing Wisconsin Environ Decade Exceptions to ASLB 830204 Initial Decision Authorizing full-scale Sleeving. Exceptions Waived for Failure to Brief or Arguments W/O Merits ML20069K5951983-04-22022 April 1983 Answer Opposing Wisconsin Environ Decade 820407 Petition for Review of ALAB-719 Which Affirmed ASLB 821210 Special Prehearing Conference Order Dismissing Petition to Intervene.Matter Raised Not Reviewable.W/Certificate of Svc ML20073D6991983-04-11011 April 1983 Request for Extension Until 830427 to File Opposition to Wisconsin Environ Decade Brief on Exceptions.Counsel Has Numerous Obligations Before ASLB & Aslab.Certificate of Svc Encl ML20073B9701983-04-0707 April 1983 Petition for Review of Aslab 830322 Decision Denying Wisconsin Environ Decade 821220 Appeal of ASLB 821210 Prehearing Conference Order.Hearing on Steam Generator Tube Degradation Issue Should Be Held.Certificate of Svc Encl ML20069F6491983-03-16016 March 1983 Brief Supporting Wi Environ Decade 830211 Exceptions to ASLB Initial Decision.Aslb Refused to Make Prerequisite Findings on Degree of Assurance Necessary to Protect Public Safety. Affidavit of Mailing Encl ML20071A1311983-02-14014 February 1983 Exceptions to ASLB 830204 Initial Decision.Affidavit of Mailing Encl ML20064H4191983-01-10010 January 1983 Replacement P 2 of 821220 Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision. Svc List Encl ML20070M0571983-01-0707 January 1983 Comments on Wi Environ Decade Statement of Inadequate Record.Statement Is Inconsistent W/Commission Regulations, Erroneous in Statement of Law,Untimely,Devoid of New Factual Info & Should Not Be Considered.Certificate of Svc Encl ML20028C3031983-01-0404 January 1983 Brief Opposing Wi Environ Decade 821220 Appeal of ASLB 821210 Special Prehearing Conference Order Denying Decade 820810 Petition to Intervene.Decade Willfully Failed to Attend Special Prehearing Conference.W/Certificate of Svc ML20028C3091983-01-0404 January 1983 Proposed Evidentiary Hearings Transcript Changes.Certificate of Svc Encl ML20070M0141982-12-30030 December 1982 Statement of Inadequate Record.Eddy Current Testing Not Proved Adequate for Sleeving Steam Generator Tubes.Record Must Be Reopened.Certificate of Svc Encl ML20070J0141982-12-20020 December 1982 Notice of Appeal from 821210 Special Prehearing Conference Order Dismissing Decade 820810 & 1105 Petitions to Intervene.Affidavit of Mailing Encl ML20070J0341982-12-20020 December 1982 Brief Supporting Appeal from 821210 Special Prehearing Conference Order Denying 820810 Petition to Intervene & Request for Extension of Time to Complete Brief.Dismissal of Petition on Stated Grounds Contrary to Law ML20070H4011982-12-20020 December 1982 Proposed Findings of Fact & Conclusions of Law in Form of Proposed Initial Decision Re Repair of Corroded Steam Generator Tubes by Inserting Sleeves.Certificate of Svc Encl ML20027E3171982-11-0505 November 1982 Contentions Re Steam Generator Replacement,Supplementing 820810 Petition to Intervene ML20027D4691982-11-0202 November 1982 Testimony of Wd Fletcher Re Adequacy of Eddy Current Testing.Certificate of Svc Encl.Related Correspondence ML20069J3451982-10-20020 October 1982 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20065G3861982-09-28028 September 1982 Amend to Wi Environ Decade 820810 Petition to Intervene Including Affidavits Requesting Wi Environ Decade to Intervene on Affiant Behalf.Certificate of Svc Encl ML20063J4521982-08-31031 August 1982 Reply Brief Supporting Wi Environ Decade 820721 Motion Concerning Litigable Issues & in Response to Licensee 820809 & 24 & NRC 820812 Responses.Contentions Timely & Relevant. Certificate of Svc Encl 1997-06-09
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
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WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266 o
) 50-301 9 'MM/'/ q (Point Beach Nuclear Plant, ) (OL Amendnent) ^ '
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Units 1 and 2) ) g i'
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l 5 LICENSEE'S SUPPLEMENTAL RESPONSES TO DECADE /S ! 'S 1 FIRST INTERROGATORIES AND REQUEST FOR T,\ , ,
PRODUCTION OF DOCUMENTS ON THE FULL-SCAL ',3)
,f3 SLEEVING PROGRAM \
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Licensee herein is providing supplemental information in response to Decade's above-capti~oned Interrogatories No. 7, 8, 10, 13, 14, 17 and 18 which Licensee has obtained subse-quently to its March 1, 1982 response.
Copies of identified documents are available for in-spection at the offices of David K. Porter, Wisconsin Electric
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Power Company, 231 West Michigan Street, Milwaukee, Wisconsin.
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B205050012 820430 1 PDR ADOCK 05000266 0 PDR
- 7. State the preliminary and final results of tests performed (i) to demonstrate the corrosion and/or cracking resistance of thermally treated Inconel 600 to primary and/or water, (ii) verify the corrosion and/or cracking resistance of the transi-tion of the lower joint of the sleeve, (iii) to verify the
. corrosion and/or cracking resistance of the upper joint of the sleeve; (iv) to verify leak limiting capabilities of the upper joint of the cleeve, (v) to verify the structural strength and.
leak tightness of the upper and -lower joint of the sleeve after cyclical loading and during accident conditions, (vi) to verify the internal pressure capabilities of sleeve joint, and (vii) any and all tests related to sleeving either not specifically referenced in the Sleeving Report and/or commenced subsequent to preparation of the Sleeving Report; and, with respect to each of the foregoing, provide all'detailstof the tests, if any.
Response
In addition to the documents identified in Licensee's response dated March 1,1982, the following documents contain information regarding this interrogatory:
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a 1. Report, NRC,' February 1982, NUREG 0886, " Steam Generator Tube
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Experience". .,
- 2. Report, EPRI, " Steam Generator Owners Group Plant, Superintendent and Plant Chemist Meeting of November 19-20, 13nE1".
- 3. Report, EPRI, February 1982, " Review of Intergranular Attack (IGA) of Alloy 600 Steam Generator Tubing".
- 4. Report, EPRI, April 13, 1982, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Cracking Resistance of Inconel Alloy 600".
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- 8. State any and all studies, analyses or consideration of any kind given to the environment of either primary or secondary water in the annulus between the sleeve and the tube and/or to the poten-f al corrosive processes that might occur in that environment, apart .
from that specifically stated in Section 6.1 of +5? Sleeving l Report Jr in Section 6.1 of the San Onofre Repais. Report.
Response
In addition to the documents identified in Licensee's. response dated March 1, 1982, the following documents contain information regarding this interrogatory:
- 1. Letter, Sol Burstein, April 1, 1982, Response to G. H. Neils letter dated February 2,1982. '
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- 10. State any and all studies, analyses or consideration of any kind given to the inspectability and the accuracy of inspections of sleeved tubes, including but not limited to any results of inspec-tion of sleeved tubes in the field at any nuclear electric gener-ating plant, apart from that specifically stated in Section 7 of the Sleeving Report of Section 7 of the San onofre Repair Report.
Response
In addition to the documents identified in Licensee's response dated March 1,1982, the foll'owing documents contain information regarding the interrogatory:
- 1. Letter, Sol Burstein, April 1,1982, Response to G. H.Neils letter dated February 2,1982.
- 2. Memorandum, J. Schweitzer, March 5, 1982, " Point Beach Nuclear Plant- Unit 1 Spring 1982 Steam Generator Outage".
- 3. Letter, C. W. Fay,. January 25, 1982, " Sleeving Demonstration Pro-gram Point Beach Nuclear Plant Unit 1".
- 4. Memorandum, G. D. Frieling, March.16,1982, " Steam Generator Inspection Point Beach Nuclear Plant Unit:1".
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. 13. Please list all defects in steam generator tubes at Point Beach Nuclear Plant by unit, steam generator, row, column, date observed, and percent defect observed, which were at a height of 22" or higher ,
from tube end subsequent to 1975. '
Response
i In addition to the documents identified in Licensee's response dated March 1,1982, the following documents contain information regarding !
this interrogator $y:
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- 1. Report, Westinghouse Field Service Report, "WEP-23, Unit 1 October 1981 Outage".
- 2. Memorandum, J. Schweitzer, March 12,1982, " Unit 1 Steam Gener- ,
ator Tube Plugging History". l
- 3. Letter, C. W. Fay, April 16, 1982, LER 82-007/01T-0, Notification of Degraded Steam Generator Tubes.
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, 14. State any and all studies, analyses or consideration of any kind l
given to observed defects in steam generator tubes at a height of 22" or higher from the tube end subsequent to 1975.
, Response l
l
, . In addition to the documents identified in Licensee's response dated March 1, 1982, the following documents contain information regarding this interrogatory:
- 1. Memorandum, T. Colburn, March 5,1982, " Summary of the January 27, 1982 Meeting to Discuss Unit 1 Eddy Current Inspection Interval".
- 2. Report, Westinghouse FSR, WEP 23, " Unit 1, October 1981 Outage".
- 3. Letter, C. W. Fay, April 16, 1982, LER 82-007/01T-0, Notification of Degraded Steam Generator Tubes.
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, . 17. State any and all studies, analyses or consideration of the '
fall 1981 demonstration sleeving program at Point Beach Nuclear Plant Unit 1, apart from that included in the Sleeving Demonstra-
- tion Report.
l Response i i'
The following documents contain information regarding this interrogatory: !
- 1. Letter, C. W. Fay, January 25, 1982, " Sleeving Demonstration !
Program Point Beach Nuclear Plant, Unit 1" (Proprietary)
I ,
- 2. Westinghouse Field Service Report, WEP-24, " October / November, 1981 Channel Head Decon, Mechanical Plug Removal, Explosive Plug i Removal and Tube Sleeving.
- 3. Letter, Sol Burstein, April 1, 1982, Response to G. H. Neils
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t letter dated February 2, 1982. i i
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. 18. State the primary-to-secondary observed leak rate in Point Beach Nuclear Plant Unit 1 subsequent to completion on the fall 1981 sleeving demonstration program, including but not limited to the daily variation in such leak rate.
Response
. - The initial response to this interrogatory included the calcu-lated primary-to-secondary leak rates up to February 22, 1982. The follow-ing leak rates were calculated subsequent to February 22, 1982.
Date Leak Rate (GPD) 3/4/82 37 3/5/82 40 3/8/82 41 3/10/82 45 3/15/82 46 3/18/82 48 3/25/82 52 3/25/82-4/12/82 Unit 1 Outage 4/13/82 <10 Respectfully submitted, SHAW, PITTMAN, POTT & TROWBRIDGE By . r s BMeW. Churchill Delissa A. Ridgway Counsel for Licensee 1800 M St., N.W.
Washington, D.C. 20036 (202) 822-1000 Dated: April 30, 1982 l
. \
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,Before the Atomic Safety and Licensing Board In the Matter of )
)
WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266
) 50-301 (Point Beach Nuclear Plant ) (OL Amendment)
Units 1 and 2) )
AFFIDAVIT OF DAVID K. PORTER County of Milwaukee )
- ss State of Wisconsin )
DAVID K. PORTER, being duly sworn according to law, deposes and says:
- 1. I am Manager of the Nuclear Engineering Section of the Nuclear Power Department of Wisconsin Electric Power Company. I graduated from the University of Illinois with a bachelor of science degree in electrical engineering in 1965. I then spent four years in the U.S. Navy's Nuclear Power Program which included one year in training and three years of reactor operator experience as an engineering officer aboard a nuclear powered cruiser. I joined the Nuclear Projects Office of Wisconsin Electric in 1969 and have been involved in various engineering assignments relating to the Point Beach Nuclear Plant and preconstruction nuclear projects since that time. As Manager of the Nuclear Engineering Section, I am responsible for providing technical, licensing, and engineering support to the Point Beach Nuclear Plant. These responsibilities include the technical review of plant equipment and repair specifications, and implementation of U. S. Nuclear Regulatory Commission ("NRC") licensing actions involving Wisconsin Elec-tric's operating nuclear facilities. I am personally familiar with Wisconsin
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Electric's activities concerning inspection and repair of the Point Beach Nuclear Plant steam generators and our application before the NRC with respect to these activities.
- 2. I have prepared or participated in the preparation of " Licensee's Supplemental Responses to Decade's First Interrogatories and Request for Production of Documents on the Full-Scale Sleeving Program", dated April 30, 1982. The information contained in those responses is true and correct to the best of my knowledge and belief.
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